Ethics and Compliance

Please click on the attached links to learn more about our Ethics & Compliance Program:

Our Ethics Helpline

If you wish to report a suspected violation of company policy or the law, please contact the helpline:

As we interact with customers to drive Company business, we do this in an ethical and compliant manner.  Driving business and behaving ethically are not at crosscurrents with each other.  The most successful businesses do things the right way.  Customers want to do business with ethical companies; in fact, research tells us that “ethical” companies have higher sales, profits, and repeat-business than “unethical” companies.  As we call on customers each day, our focus is on patients and extending and enhancing human life.

 

We follow all major healthcare laws, including but not limited to:

  • Anti-Kickback Statute
  • Federal False Claims Act
  • Food, Drug and Cosmetic Act
  • Physician Payments Sunshine Act (“Open Payments”)
  • Prescription Drug Marketing Act
  • Health Insurance Portability and Accountability Act

We also follow guidance from:

  • Office of Inspector General (OIG) for the Department of Health and Human Services
  • Food and Drug Administration (FDA)
  • PhRMA Code

This translates to the following guiding principles as we interact with customers:

  • We don’t pay customers to use our products
  • We promote our products for FDA-approved, “on-label” indications
  • We use fair balance in all of our promotional messaging
  • We accurately record and report HCP spend
  • We respect patient privacy